This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Temple Baptist Church operated a child care center that included a religious curriculum and a policy of spanking children for misbehavior, which the church believed was biblically mandated. The church ceased obtaining a state license for the center in 1980, asserting that doing so subordinated its religious beliefs to the state. The Health Services Division sought to enjoin the church from operating the center without a license, citing regulations prohibiting corporal punishment and requiring licensure for child care facilities (paras 2-3).
Procedural History
- District Court of Santa Fe County: Granted judgment to the Health Services Division, enjoining the church from operating its child care center without a license.
Parties' Submissions
- Plaintiff-Appellee (Health Services Division): Argued that the church's operation of the child care center without a license violated state law and that the prohibition on corporal punishment was a necessary regulation to protect children (paras 1, 20).
- Defendants-Appellants (Temple Baptist Church): Contended that the licensing requirement and the prohibition on spanking infringed on their First Amendment right to freely exercise their religion (paras 1, 3).
Legal Issues
- Did the licensing requirement for child care centers violate the church's First Amendment right to freely exercise its religion?
- Did the prohibition on corporal punishment infringe on the church's religious practices?
Disposition
- The Court of Appeals of New Mexico affirmed the district court's decision, holding that the licensing requirement and the prohibition on corporal punishment did not violate the church's constitutional rights (para 27).
Reasons
Per Chavez J. (Bivins and Minzner JJ. concurring):
The court applied the U.S. Supreme Court's decision in Employment Division v. Smith ("Smith II"), which held that generally applicable, religion-neutral laws do not require a compelling governmental interest to justify their application, even if they incidentally burden religious practices. The court found that the licensing requirement and the prohibition on corporal punishment were generally applicable and religion-neutral laws (paras 17-18).
The court rejected the church's argument that the case involved "hybrid rights" (a combination of free exercise and parental rights) as described in Smith II, noting that no individual parents had claimed their rights were infringed (paras 23-24). Additionally, the church had not pursued available administrative avenues to seek an exemption from the corporal punishment regulation, rendering that claim unripe for review (paras 19-20).
The court declined to consider the church's argument under the New Mexico Constitution because it was raised for the first time in supplemental briefing and not at trial (para 25). The court concluded that the church was not entitled to relief under federal constitutional law and affirmed the district court's decision (paras 26-27).